Privacy Policy

Welcome to Circles, developed by Circles Inc. Circles is a group loyalty and rewards application with integrated social features including group messaging, shared calendars, itineraries, and multimedia sharing. Your privacy is important to us and we are committed to protecting your personal data.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Circles app and related services (collectively, the "Service"). By using Circles, you agree to the terms of this Privacy Policy. If you do not agree, please do not use the Service.

1. Information We Collect

A. Information You Provide

• Account Information: Name, email address, phone number, profile picture, and other registration details you supply when creating your account.
• Group Activity Data: Messages, shared media (photos, videos, documents), calendar events, itineraries, to-do lists, and other content you create or share within your Circles.
• Interest & Preference Data: Group interests, lifestyle categories, and preferences you select to help us tailor rewards and offers to your Circle.
• Payment Information: If applicable, payment details for premium features or in-app transactions, processed securely through third-party payment providers. Circles does not store your full payment credentials.

B. Information Collected Automatically

• Device & Technical Data: IP address, device type, operating system, browser type, unique device identifiers, and app version.
• Usage Data: Engagement metrics, feature usage patterns, group activity levels, and interaction data used to improve services and qualify your Circle for rewards.
• Location Data: Approximate location (based on IP or device settings, if enabled) to provide localized offers and experiences. You may disable location access through your device settings.
• Cookies & Similar Technologies: We use cookies and similar tracking technologies for analytics, functionality, and to enhance your experience.

2. How We Use Your Information

We use the information we collect to:

• Provide, operate, and maintain the Service, including group messaging, calendars, itineraries, and rewards features.
• Analyze group interests and activity to qualify Circles for exclusive, curated rewards and offers.
• Personalize your experience and the offers presented to your Circle.
• Improve app functionality, performance, and security.
• Send notifications, service updates, and promotional communications (with opt-out options).
• Comply with legal obligations, enforce our terms, and prevent fraud or abuse.

3. The Rewards System & Your Data

Circles' group rewards engine uses aggregated and anonymized group-level data — such as shared interests, group activity frequency, and lifestyle preferences — to match your Circle with relevant offers from our business partners. Individual message content is never shared with advertisers or business partners. Rewards qualification is based on group-level engagement patterns, not the content of your private conversations.

4. Data Sharing & Disclosure

We may share data with the following categories of recipients:

• Circle Members: Content you share within a Circle is visible to the members of that Circle.
• Service Providers: Trusted third-party vendors who assist with cloud hosting, analytics, payment processing, and app infrastructure, bound by confidentiality agreements.
• Business Partners: To deliver group rewards, offers, and promotions. Data shared with partners is aggregated and anonymized wherever possible. We do not share individual chat content with partners.
• Legal Authorities: When required by law, regulation, legal process, or to protect the rights, property, or safety of Circles Inc., our users, or the public.

We do not sell your personal data to third parties.

5. Data Security

We implement industry-standard security measures, including encryption in transit and at rest, access controls, regular security audits, and secure development practices. However, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.

6. Data Retention

We retain your personal data for as long as your account is active or as needed to provide the Service. If you delete your account, we will delete or anonymize your personal data within 30 days, except where retention is required by law or for legitimate business purposes (such as resolving disputes or enforcing agreements).

7. International Data Transfers

Circles is operated by Circles Inc. in Canada. Your data may be processed in Canada or other jurisdictions where our service providers operate. We ensure appropriate safeguards are in place for international data transfers, including standard contractual clauses where applicable.

8. Your Privacy Rights

Depending on your jurisdiction, you may have the right to:

• Access, correct, or delete your personal data.
• Opt out of marketing communications at any time.
• Restrict or object to certain types of data processing.
• Request portability of your personal data.
• Withdraw consent where processing is based on consent.

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

9. Children's Privacy

Circles is not intended for users under the age of 13 (or 16 in certain jurisdictions). We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected data from a child, we will take prompt steps to delete it. If you believe a child has provided us with personal data, please contact us immediately.

10. Third-Party Links & Services

The Service may contain links to third-party websites, apps, or services. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party service you access through Circles.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify users of material changes via in-app notification or email. Your continued use of the Service after changes are posted constitutes your acceptance of the revised policy.

12. Contact Us

For privacy-related questions, concerns, or requests, contact us at:

Circles Inc.
Email: [email protected]
8 Storey Drive, Acton